Privacy Policy

In this policy, we, our or us means Libris Pty Ltd (ACN 643 327 146) and any related entities, including its holding company and any subsidiaries. This policy applies to our website and to our software product, Libris back office (Libris or the Platform).

To provide you with the best possible service, we collect and use certain personal information about you. Your privacy is important to us and we are dedicated to ensuring your personal information remains private.

This policy sets out how we handle your personal information, consistent with the Australian Privacy Principles in the Privacy Act 1988 (Cth).

For the purposes of this policy, personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not and whether the information or opinion is recorded in a material form or not.

We review this policy periodically and may make changes at any time by publishing the amended version on our website. Where we make material changes to this policy, we will take reasonable steps to notify you (for example, by email or by a notice on our website) before those changes take effect.

In the course of operating our business and providing the Platform, we may collect a range of personal information from customers, users, prospective customers, service providers, job applicants and other individuals. We only collect personal information that is reasonably necessary for one or more of our functions or activities. The kind of information collected will depend on the nature of your dealings with us, but may include:

1. (a)
   contact and identification information, such as your name, date of birth, contact number, email address, residential and business address, and driver's licence or other identification document details;
2. (b)
   account and authentication information used to set up and access the Platform, including login credentials and electronic signatures;
3. (c)
   financial and payment information, including bank account and bank-connection details, payment card details, and tax identifiers (such as ABN or TFN) provided in connection with your use of the Platform. Where we collect your TFN, we do so in accordance with the Privacy (Tax File Number) Rule 2015 and only for purposes authorised by taxation law;
4. (d)
   business and operational data that you or your personnel enter into the Platform in the course of using its functions; and
5. (e)
   information collected from your interactions with us, including via marketing campaigns, surveys and social media.

If you do not provide us with the personal information we request, we may be unable to provide you with the full range of our services, and you may be ineligible to use some or all of the Platform. Where it is practicable and lawful, you may deal with us on an anonymous or pseudonymous basis (for example, when making a general enquiry). However, for most of our services, including access to the Platform, we will need to verify your identity.

Sensitive information. We will only collect sensitive information about you (such as biometric information collected during identity verification, or health information provided in connection with payroll functions) with your consent and where it is reasonably necessary for our functions or activities, unless we are otherwise allowed or required by law to collect it. We will handle all sensitive information in accordance with the Australian Privacy Principles and will not use or disclose it for purposes other than the purpose of collection, unless you consent or an exception applies.

Most of the personal information we collect will be collected directly from you, for example when you contact or interact with us, set up an account or are onboarded to the Platform, respond to a job advertisement, or attend an event hosted by us.

We may sometimes collect your information from third parties, such as online services you have granted us access to, parties who refer you to us, an entity that engages us where you are its representative, contractors we engage, or marketing agencies and similar providers.

When you visit or interact with our website, the Platform or any other online platform operated by us (Platforms), we and our service providers may use technologies that automatically record information about how the Platform is accessed and used (Usage Data). Usage Data may include your IP address or other device identifier, the pages and content you click on and view, your approximate location, browser and device type, and the date and time of your visit. Usage Data is usually non-identifying, but if it can be used to identify you, we will treat it as personal information.

We may use cookies (data files placed on a device used to visit a Platform) to keep track of preferences and compile aggregate data about Platform traffic and online interactions. You can configure your browser to disable or reject cookies, but if you do, some features of the Platforms may not be available to you.

We collect, use and disclose your personal information for a range of purposes, including to:

1. (a)
   provide you with the Platform and our related services, and onboard and support you;
2. (b)
   process and verify payments authorised by you;
3. (c)
   respond to your enquiries, concerns or complaints;
4. (d)
   assess applications from prospective job applicants or contractors;
5. (e)
   customise, measure and improve our services, including through data analytics, product planning and research. Where we use automated tools or artificial intelligence to process your personal information, we will ensure appropriate human oversight, and our use of automated decision-making is described further in clause 5 below;
6. (f)
   send you news, event information and, where permitted, direct marketing; and
7. (g)
   comply with the law, including a lawful request from law enforcement, and for security and safety purposes.

The Platform includes features that rely on artificial intelligence and machine learning technologies (AI Features), including automated tools used in the Platform's functions. This clause explains how personal information is handled in connection with those AI Features.

Where you or your personnel input data into the AI Features, that data is processed only to generate outputs for you and to provide the relevant function of the Platform. We do not collect, retain or use the data you input into the AI Features for our own purposes, and in particular we do not use it to train, develop or improve our own or any third party's AI models, except to the extent reasonably necessary to provide the Platform to you, to improve the Platform using aggregated or de-identified data that is not reasonably capable of identifying you, or as required or authorised by law.

Some AI Features are provided using third-party artificial intelligence models and infrastructure. To deliver these features, data you input may be transferred to, and processed by, those providers on servers located outside Australia. Any such disclosure is handled in accordance with clause 8 (Cross-border disclosure) below.

We do not use AI Features or other computer programs to make, or to do a thing that is substantially and directly related to making, a decision that could reasonably be expected to significantly affect your rights or interests, in a way that relies solely on automated processing. Where automated processing is used to materially assist such a decision, we endeavour to ensure that a human is meaningfully involved in the decision and, where required by applicable law, we will tell you the kinds of personal information used and how the processing affects the decision. You may request further information or a review of such a decision by contacting us using the details below.

We may disclose your information to third parties who perform a function or service on our behalf, including secure data storage and hosting providers, information technology service providers, payment and bank-connection providers, mail distribution providers, debt collection agencies, and professional advisers such as accountants and lawyers. We may also disclose your information where required or authorised by or under law, or in connection with a proposed or actual corporate transaction such as a merger, acquisition or sale of assets (in which case the recipient will be subject to obligations of confidentiality). We will not sell or disclose your information to a third party for the purposes of direct marketing without your informed consent.

We will only send you direct marketing material if you would reasonably expect to receive it or you have consented. Each marketing communication will include a simple and prominent means for you to opt out, and we will give effect to any opt-out request within a reasonable period. You may also ask us not to use or disclose your personal information for direct marketing at any time by contacting us using the details below. Our electronic marketing complies with the Spam Act 2003 (Cth).

Our preference is to use service providers based in Australia. However, some of our service providers, including cloud hosting and artificial intelligence model and infrastructure providers used to deliver the AI Features described in clause 5, may store or process your personal information outside Australia. Where we disclose your personal information to an overseas recipient, we will take reasonable steps to ensure that the overseas recipient handles your personal information in accordance with the Australian Privacy Principles. We may rely on an exception to this requirement where the overseas recipient is subject to a law or binding scheme that is substantially similar to the APPs (including mechanisms you can access to enforce that protection), or where you have provided your informed consent.

The security of your personal information is important to us, and we take reasonable steps to protect it from misuse, interference, loss and unauthorised access or disclosure, including using encryption in transit and at rest, hosting on servers in secure facilities, reviewing the security measures of our third-party suppliers, and ensuring our personnel are aware of this policy.

No method of transmission or electronic storage is completely secure. While we take all reasonable steps to protect your personal information, we cannot guarantee its absolute security. If a data breach occurs and there is a likely risk of serious harm to you, we will notify you and the Office of the Australian Information Commissioner in accordance with applicable law, including, where it applies, the Notifiable Data Breaches scheme.

If you are a user of our Platforms, you can update much of your personal information at any time via your account. On written request, we will provide you with a copy of the personal information we hold about you within 30 days, unless there is a lawful reason not to, and we will take reasonable steps to correct it where it is inaccurate, out of date, incomplete, irrelevant or misleading. We will not charge you for making an access or correction request, but we may charge a reasonable fee for providing access if the request requires significant effort to fulfil.

When we no longer need your personal information for a permitted purpose and are not required to keep it by law, we will take reasonable steps to destroy it or ensure it is de-identified.

If you have a concern or complaint about how we have handled your personal information, please contact us in writing using the details below. We will endeavour to respond within 30 days of receipt. If your complaint is not satisfactorily resolved, you may refer it to the Office of the Australian Information Commissioner.

If you have questions or suggestions, please contact us at office@libris.au. If we change this policy, we will post the changes on our website at libris.au. Please refer back to this policy to review any amendments.